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[23] An internal memorandum by an attorney for the RJ Reynolds tobacco company described their strategy as, "To paraphrase General Patton, the way we won these cases was not by spending all of our money, but by making that other son of a bitch spend all [of] his." [23] The third wave of tobacco litigation was much more successful for plaintiffs, with plaintiffs winning 41% of cases between 1995 and 2005

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The findings also offer directions for further research into the pathogenesis of arthritis